As we’ve previously discussed, Prop 37 has two important labeling components: (1) a requirement that foods made with genetic engineering are labeled as genetically engineered, and (2) a restriction on labeling genetically engineered foods and processed foods as “natural.” The language of Prop 37 suggests that each of these components has a different date on which it becomes enforceable.

Section 110809, titled “Disclosure With Respect to Genetic Engineering in Food,” makes clear that companies would have almost two years before Prop 37’s genetically engineered food labeling requirements take effect...